In a statement released last week (27 November 2025), Huw Irranca-Davies, Deputy First Minister and Cabinet Secretary for Climate Change and Rural Affairs, stated that if the UK Government does not grant the legal flexibility required, Wales could be left with “no DRS in Wales”.
The comment came as Wales opened applications for the Deposit Management Organisation (DMO) that will operate its DRS.
‘No DRS in Wales’
In a statement addressing plans for the scheme, the Welsh Government said it had moved to secure legal certainty for all nations planning a DRS.
The Minister for Climate Change explained: “The Welsh Government has therefore formally proposed an exclusion for the Deposit Return Scheme in Wales to the United Kingdom Internal Market Act 2020 (UKIMA), noting that the scope of the scheme is fully within devolved competence.
“We have also been clear that should that exclusion as requested not be agreed, this would lead to the scenario where there would be no DRS in Wales, and as such an exclusion would be required for the schemes in other nations.”
The Internal Market Act has been a consistent issue in the road to a UK DRS – with the exclusion of glass from the formal exemption leading to the Scottish scheme being delayed.
Ministers have now made clear that Wales will not go ahead with DRS implementation if it is not permitted to include glass.
Scotland’s delayed DRS
Scotland’s scheme, initially slated for 2022, saw its go-live date pushed to August 2023, before being further delayed.
In June 2023, then-minister Lorna Slater told Holyrood that UK Government conditions, particularly the requirement to remove glass, left Scotland with “no option” but to delay implementation until at least October 2025.
Shortly afterwards, the scheme was effectively paused. The UK Government later announced that all DRS plans across the UK should align to a single start date of 1 October 2027, covering England, Northern Ireland and Scotland.
The difficulties with the Scottish DRS start date led to waste management company Biffa suing the Scottish Government for damages of around £166 million after being appointed as sole logistics provider for the scheme in July 2022.
The case went to hearing in October 2025, with the judge’s decision yet to be announced.
Progress for Welsh scheme
Wales first announced that it would exit the UK DRS process in November 2024, stating that the nation will continue to develop a DRS which “delivers for Wales”.
Irranca-Davies said that the decision was made due to issues “caused by the United Kingdom Internal Market Act 2020”, which includes the decision to exclude glass from the scheme.
Since November 2024, Welsh ministers have been engaging with producers, retailers, local authorities, recycling and reuse organisations and environmental groups and have identified two industry priorities:
- Aligning DRS implementation dates across the UK
- Adopting a phased introduction of glass and reuse to reflect differences in scheme scope across the four nations
Irranca-Davies explained: “We have made adaptations to the scheme that will both ensure we can bring forward a DRS that delivers clear benefit to Wales, by supporting the transition to reuse and building upon our world class recycling, whilst also taking a pragmatic, phased approach on glass and reuse to ensure interoperability within the UK.”
Ministers remain committed to aligning with the UK-wide start date of 1 October 2027, assuming legal clarity is secured.
However, if the UK Government refuses the exclusion, the scheme will not proceed.
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